Jeff Koeze's Blog Good Food, Good Business, and the Good Food Business


Obama’s Budget and the FDA

President Obama's budget proposal for 2010 includes $1 billion for the FDA to "increase and improve inspections, domestic surveillance, laboratory capacity and domestic response to prevent and control foodborne illness."

I have a dim understanding of the federal budget process, but I assume that it will be a bit before we have the opportunity to learn the details about this proposed spending. (And months and months until we see actual Congressional action.)

But I think it is interesting to compare this to the FDA's budget request for food safety for the current fiscal year, which is here.

The 2009 FDA request was $661.8 million, an increase of $42 million over the prior year.  This increase would have provided almost $23 million for field activities on the food side, most of which would have gone to hire additional field inspectors.

I could be wrong, but I don't think the President is proposing taking the food safety budget from $600+ million to $1.6 billion, but from $600 million to $1 billion total.

Still, we'd be looking at over a 50% increase in the food safety budget.  Moreover, if spent along the lines that the FDA has already laid out in their 2009 request, it would go a long way towards improving food safety.

I still stick to my position.  The biggest problem in our food safety system is lack of funding.  Compared with adequate funds, all the other regulatory and organizational "reforms" being so earnestly advocated are a side show.


PCA Facts Coming Out Slowly

An article in today's Atlanta Journal Constitution reports:

Texas health officials said Wednesday that a sample of peanut meal from the Texas plant tested positive for salmonella and also matched the genetic fingerprint of the salmonella implicated in the national outbreak.

Peanut products were regularly shipped between Peanut Corp.’s Blakely, Ga., and Plainview, Texas, processing plants, raising the prospect of a contamination link between the two plants, the FDA said Wednesday.

The Blakely plant’s shipments included honey-roasted peanuts, hot and spicy peanuts and other seasoned products, said Stephanie Kwisnek, a spokeswoman for the FDA. The Plainview plant shipped peanut meal to Blakely, she said.

Sundlof, of the FDA, said the agency suspects that the salmonella contamination originated from the Blakely plant and was transferred to the Plainview plant. Many more contaminated products have been traced to the Georgia facility, he said.

So much for my speculation that they weren't shipping back and forth.  But the peanut meal comment is intriguing.  I think you'd only ship peanut meal if you intended to use it to make peanut butter.  And if you look at the CDC site,  you can see that all the tests associated with illness came from peanut butter or peanut paste (which, by the way, is also peanut butter -- it just doesn't have anything added) and are a single strain -- now tied back to the Plainview plant.

I'd make the opposite inference from the one Sudlof made -- I'd assume the transfer of bacteria was from was from Plainview to Blakely, based on this article.   Infected meal is sent from Texas to Georgia to be ground into peanut butter, and there you go.

And I'd sure want to find out where that peanut meal came from.

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Regulation and the Locavores

All regulations come with unintended consequences.  In a comment about the Georgia food testing legislation I left over at Effect Measure, I pointed out:

Keep an eye on the locavores. A substantial sub-set of the let's call it "micro-producer" community views additional regulation as an attempt to stamp them out. I don't want to argue about the merits, but I think the politics will get interesting in some states...

In a response to this comment Ron says:

Jeff raises an important point. Historically, increasing regulations of this type penalize small producers, pushing the system to greater size, cost cutting and centralization, thus increasing the problem rather than solving it. Recall the spinach incident of last year, also of wide impact due to centralized post-harvest processing. Both incidents had such a high impact because a single processing plant supplied such a wide sector with product. "Economies of scale" and mistaken ideas of "efficiency" inspire greater regulatory burdens that are actually counterproductive, making our food system less safe instead of safer. This is not what is needed.

Retailer consolidation is a bigger factor in concentrating the food supply chain (earlier post here), but regulation certainly matters at the margin.

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Just When I Thought the PCA Story Couldn’t Get Any Weirder

This morning the press is reporting that the same salmonella strain that caused the initial outbreak has been isolated from peanut butter made from peanuts that were shipped from the Texas plant.  The same strain from Georgia and from Texas?

From the AP story:

An opened container of Vitamin Cottage peanut butter tested positive for the outbreak strain, which came from a Colorado resident who got sick, company vice president Heather Isely has said. Earlier, the same strain of salmonella bacteria was detected in containers of peanut butter that had been produced at a Peanut Corp. plant in Blakely, Ga.

U.S. Food and Drug Administration spokeswoman Stephanie Kwisnek said two samples of Vitamin Cottage peanut butter from two different consumers tested positive for the outbreak strain, but it was not clear how many containers were involved.

It's possible the Vitamin Cottage peanut butter was contaminated after it was opened, health officials noted. But the latest test results raise questions about how many of the outbreak illnesses — which have been attributed to the Blakely plant — came from other production facilities.

"Because of the public health risk posed by positive findings of salmonella associated with the outbreak strain at PCA's plant in Blakely, Ga., the FDA expanded its scope of inspections to include other PCA plants," said FDA spokeswoman Stephanie Kwisnek.

And from The Dallas Morning News:

Doug McBride, a spokesman for the Texas Department of State Health Services, said peanut meal at the plant in Plainview, about 50 miles north of Lubbock, was sampled Feb. 12 and tested positive last weekend.

"Our lab determined that it is the outbreak strain of typhimurium," McBride said. "We don't know what that means yet."

However, the fact the identical salmonella strain was found at both plants, more than 1,100 miles apart, suggests a cross-contamination of their product lines, health officials said.

Health officials are looking for some kind of link between the two plants.

Once again, putting on my wild speculation hat, I don't think they will find one.   I can think of no reason to ship product from one plant to  the other.  If press reports are correct, both had the capacity to roast, package, and granulate.  And freight, especially in less-than-truckload amounts, would be prohibitively expensive, I'd think.

I'm back to one of my original how did this happen? thoughts -- that these peanuts were purchased already roasted from somewhere and shipped directly to the two plants.

In the meantime, I'll be watching the CDC site to see if they post an update on the strains.

UPDATE:  Another thought.  Although the Virginia plant has not been implicated, it is at least possible that roasted nuts were shipped from Tidewater Blanching to the other two plants.  Financially, I can't see that making sense, but at this point, who knows?


No Japan Trip for Me

I was supposed to leave on Saturday for a trade show in Japan to sell peanut butter.  I had looked forward to posting shots of the trip here.

What we've heard is that the Japanese have embargoed all US products containing peanuts.  This means we wouldn't be able to provide samples, and probably would be prohibited from even showing our product.

Given that we are about to see another flood of product called back because of the FDA's pursuit of product from PCA's Texas plant, the Japanese position seems sensible.  Who knows what will be on the FDA web site next?

Our Japanese retailers have been kind enough to contact Japanese officials and see if we can slip through this net, and we've provided the officials with assertions that we make peanut butter here from raw peanuts.  But the answer is no.  I'm disappointed, but I understand.

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The Paradox of More Regulation

Fascinating  talk, and something to consider while working out how to improve food safety after the PCA scandal.


Bankruptcy Causes More PCA Confusion, Delay

This morning the papers are reporting for the second time that all products from the PCA Texas plant are being recalled.  I say second time because officials in Texas had previously announced such a recall on February 12.

So, what's up with that?  It appears to me that some food manufacturers, knowing that they had purchased from PCA in Texas, stepped up in the days following the initial recall and called back product.  Others, it seems clear, waited.  The questions is Why?

My assumption is that many food makers waited because the legal authority of Texas officials ends in Texas.  So without pressure or a public announcement from the FDA, or from officials in their own states, they sat on their hands.

Meanwhile, in Texas, state officials were apparently waiting for PCA to step up, open their records, and start contacting their customers.  PCA, in bankruptcy, had no reason to do that, and maybe under the bankruptcy laws have been prevented from doing so.

Meanwhile, the FDA was indeed following up with manufacturers who purchased from the Texas plant and goading those who had into issuing recalls.  But the public did not know about this, because the agency never issued a public statement or updated its web site to indicate in any way that they were following up on the Texas recall.

I found out last Friday.  A supplier who had earlier assured us in a letter that it had purchased no product from the Blakely, Georgia PCA plant issued a press release recalling two products made with peanuts from the Texas plant.  We spotted this soon after it was posted on the FDA's site.

We immediately pulled the one product we had purchased (bulk milk chocolate peanuts) from our retail stores and secured our inventory.  I then called our local FDA office and our regional FDA recall coordinator in Detroit.  By the end of the day we had our own press release out, which hit the Michigan media around 5 PM.

With the  new announcement things might start moving a bit faster, but more than a week has been lost.

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Can We Test Our Way to Food Safety?

The Georgia Senate has passed a bill to require food testing and submission of positive test results to the state.   If properly funded -- and this is a huge if -- I have no doubt such a plan would help improve food safety.  But it is not a silver bullet.

The testing of food destroys the food. So you can never test 100% of the food and say that it is 100% safe. You have to take samples of the food (called your sampling plan), and based on the results of the test, you can infer that the food is safe.  But different foods and different processes require different sampling plans.  It also matters exactly what you are testing for.

Determining effective sampling plans for probably hundreds of different foods in hundreds of different settings would be massive, and I would add, highly technical task. (Unless Georgia goes to some crude one size fits all regime, or maybe S, M, L.) It is worth pointing out that a deep knowledge of statistical inference and sampling strategy design is not going to part of the skill set of the typical environmental health specialist.

The bill provides that if a company submits a testing plan as part of a food safety plan, and if the state approves it, then they can use that plan. The approvals would be a slightly less massive job. The prime benefit would be the advantage early on in getting a look at everybody's testing strategies. Some would be highly sophisticated, and could be used as models.

Before everyone jumps on the more testing bandwagon we need to be clear that monitoring a test regime of this magnitude will require a lot of staff and a lot of computer hardware and office space.

I'll also point out that the easiest thing in the world for an unscrupulous food manufacturer to do is to evade a regime like this. It is just as easy to pull your samples from a bulk package of previously tested product as it is off your line.

I'd rather see the money and effort go into boots on ground -- more, better trained inspectors and more frequent inspections.


Is Third Party Certification the Answer? An Answer?

There has been some coverage of the fact that PCA's Georgia plant had obtained a "superior" rating on an inspection by AIB, apparently required by Kellogg's.  Read this fabulous post by Jim Prevor at Perishable Pundit on this topic.

When my company used to be an ingredient supplier we were required by several customers to be inspected by AIB International (then the American Institue of Baking).   This was before my time, so I don't really know a lot about the effectiveness of private third-party food plant inspectors.  Nevertheless, all kinds of pundits and bloggers, who know even less than I do, seem to be advocating for more extensive certification as part of the solution to improving food safety.  Like many of the supposed solutions, this is no magic bullet.


A Nice Little Gesture from Zingerman’s

Zingerman's in Ann Arbor has played a big role in getting the news about our peanut butter out there in the world.  Several years ago I went down to Zingtrain to do a seminar on retail merchandising, and presented our Cream Nut All-Natural in Peanut Butter in official Zingerman's "what's so great about [fill in product]" format.  The result was a sale to several of my classmates.

Zingerman's themselves took awhile to come around and buy our product, but they do an amazing job and truly believe in partnership with their vendors.

This morning, out of the blue, I got a short little note of thanks from Ari Weinzweig.  How many retailers actually thank their suppliers?  A great little touch, and another thing I need to steal from their playbook.